G.R. No. 77875 February 4, 1993
PHILIPPINE AIRLINES, INC., petitioner, vs. ALBERTO SANTOS, JR., HOUDIEL MAGADIA, GILBERT ANTONIO, REGINO DURAN, PHILIPPINE AIRLINES EMPLOYEES ASSOCIATION, and THE NATIONAL LABOR RELATIONS COMMISSION, respondents.

FACTS

The individual respondents, Port Stewards of petitioner Philippine Airlines, Inc. (PAL), had salary deductions for losses of inventoried items. They filed a formal grievance on November 4, 1984, pursuant to Step 1 of the Collective Bargaining Agreement (CBA). The grievance, received by the secretary of division head Mr. Reynaldo Abad on November 21, 1984, was not acted upon as Mr. Abad was on vacation leave. On December 5, 1984, the grievants, noting the lack of reply within the CBA’s five-day period for resolution, declared the grievance resolved in their favor. Upon Mr. Abad’s return on December 7, 1984, he scheduled a meeting. Meanwhile, the individual respondents refused to conduct ramp inventory on specified dates in December 1984. After a meeting where the grievance was denied, Mr. Abad required explanations for the refusal to conduct inventory. The respondents cited the CBA provision that the grievance was deemed resolved in their favor due to inaction. Finding the explanations unsatisfactory, PAL imposed suspensions without pay of varying durations. The labor arbiter dismissed the complaint for illegal suspension, but the National Labor Relations Commission (NLRC) reversed the decision, declaring the suspensions illegal and ordering payment of withheld salaries.

ISSUE

Whether the NLRC acted with grave abuse of discretion in declaring the suspensions of the individual respondents illegal based on the interpretation of the CBA’s grievance procedure.

RULING

The Supreme Court denied the petition and affirmed the NLRC decision. The Court held that under Section 2, Article IV of the PAL-PALEA CBA, the division head must answer the grievance within five days from its presentation. Failure to act within this period results in the grievance being resolved in favor of the aggrieved party. The fact that division head Reynaldo Abad was on leave when the grievance was filed did not excuse compliance. The company could have assigned an officer-in-charge to attend to such duties. The employees’ knowledge of Abad’s leave did not prevent the application of the CBA provision. The Court emphasized the policy of social justice and the constitutional mandate to protect labor, stating that interpreting the CBA otherwise would allow management to delay resolution by invoking an officer’s absence, to the detriment of workers. The respondents’ belief in good faith that the CBA provision applied was justified. Therefore, the suspensions were illegal, and the employees were entitled to payment of their salaries for the suspension period.